USPTO Patents Application 10582547

Att'y Docket: 2029.02

Discussion of Claim Rejections under 35 USC 101

Claim 13 was rejected under 35 USC 101 for not being tied to a particular machine and
not performing a transformation.

In response, Applicant amended Claim 1 3 to tie each step to a particular processing unit
for a specific performance of a transformation. Thus, the claim rejection should be withdrawn.

Discussion of Claim Rejections under 35 USC 103

Claims 1-7 and 12-26 were rejected under 35 USC 103(a) as being unpatentable over
Guenebaud (US Pub. No. 2006/0053457) in view of Kudumakis (US Pub. No. 2003/0128845).

In response, Applicant amended Claims 1,13 and 21 and respectfully disagrees with the
Examiner.
Claim 1

The amended Claim 1 provides that

A distorted contents generating apparatus comprising:

an initial value generation unit for generating an initial
value used to generate a random number for a distorting
filter;

a random number generation unit for generating a random
number for the distorting based on the initial value
transmitted from the initial value generation unit;

a filter generation unit for generating a distorting filter
based on the initial value and the random number;

a data filtering unit for distorting an- original contents
into distorted contents by filtering the original contents
with the distorting filter;

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an encoding unit for encoding the distorted contents output
from the data filtering unit;

a signal insertion unit for encrypting the initial value
information generated by the initial value generation unit and
inserting the encrypted filter initial value into the
distorted contents; and

an image correction unit for inserting image correction
information into the encoded distorted contents transmitted
from the encoding unit.

Fig. 9

Omm IMAGE 0ISTORTE.D IMAGE

Fig. 9 of the present invention

The present invention provides an apparatus for protecting copyrighted original image or
contents. Background art of the specification describes downsides of traditional copyright

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protection techniques including a DRM (Digital Right Management) and this invention overcame
such downsides by providing a means to distort original image into distorted one, transmit the
distorted image and then restore the original image. Thus, the present invention comprises four
major elements: a distorting filter, encoding unit, decoding unit and contents recovering unit.
Neither Guenebaud, Kudumakis, nor combination thereof teaches or discloses the claimed
invention.

First, Guenenbaud provides a digital signal-processing module for encoding and decoding
digital signals. Even if Guenenbaud mentioned "filtering unit," it does not disclose "distorting
filter" to distort original image or contents. To the contrary, it is obvious from the context that
Guenebaud' s filtering does not involve the processing of "distorting." In addition, Guenebaud' s
filtering does not use the initial value and the random number as in the claimed invention.

Second, due to lack of distorting processing, Guenenbaud does not have the image
correction unit of the present invention. The Examiner mentioned Guenebaud' s inserting image
date in paragraph 0112 corresponds to the image correction unit, but Guenebaud' s inserting
image is to process two streams (or more) of digital data simultaneously, not to insert image
correction information into the encoded distorted contents. Guenebaud's inserting image
supports that Guenebaud does not involve the processing of distorting images.

The combination of elements as claimed is not taught or suggested by the references
alone or in combination. Furthermore, one of ordinary skill in that art, would not look to either
Guenebaud or Kudumakis to achieve the advantages of the present invention. Combining
Guenebaud and Kudumakis does not in any way teach or suggest the claimed invention.

Therefore, Applicant respectfully submits Claim 1 is now patentable.

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Claim 6

Claim 6 depends on now patentable Claim 1 with additional limitations of "an initial
value encrypting unit for encrypting the initial value information generated by the initial value
generation unit. Again, neither Guenebaud nor Kudumakis discloses this kind of unit.
Encrypting initial value

Therefore, Applicant respectfully submits Claim 6 is now patentable.

Other claims

Claims 2-12 depend on now patentable Claim 1 and thus, Applicant respectfully submits
Claims 2-12 are now patentable.

Method Claims 13-26 include the limitations of Claim 1 and thus, the arguments for
Claim 1 above apply to these claims as well. Therefore, Applicant respectfully submits Claims
13-26 are now patentable.

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CONCLUSION

The applicant now believes that the rejections are obviated by this amendment, and the
application is now in condition for allowance: therefore, reexamination, reconsideration and
allowance of the claims are respectfully requested. If there are any additional comments or
requirements from the examination, the applicant asks for a non-final office action.

Very truly yours,
Park Law Firm

4/T. 2010 Bv: -^j^^CS

By:_

Choongseop 1 Lee, Ph.D.
Regis. No. 57,051

3255 Wilshire Blvd., Suite 1110
Los Angeles, California 90010
Tel: (213) 389-3777

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